U.S. Court of Appeals for the Fifth Circuit, 1964

Leonard Hyatt and Maudie Hyatt v. Commissioner of Internal Revenue

U.S. Court of Appeals for the Fifth Circuit · Decided January 31, 1964 · Breitenstein, Bell

325 F.2d 715 (Federal Reporter, Second Series)

Counsel

John Peace, Stanley Schoenbaum, San Antonio, Tex., for petitioners. ■, Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Atty., Dept. of Justice, Crane C. Hauser, Chief Counsel, I. R. S., Eugene F. Colella, Atty., I. R. S., David O. Walter, Earl J. Silbert, Stephen B. Wolfberg, Michael I. Smith, Attys., Dept. of Justice, Washington, D. C., for respondent.

Cases that cite this one

7 later published cases cite this decision.

Ledoux v. Commissioner (United States Tax Court 1981)
Kingsbury v. Commissioner (United States Tax Court 1976)
Kathman v. Commissioner (United States Tax Court 1968)
Pridemark, Inc. v. Commissioner (United States Tax Court 1964)
Mingo v. Commissioner (5th Cir. 2014)
Furrer v. Commissioner (United States Tax Court 1976)
Realty Loan Corp. v. Commissioner (United States Tax Court 1970)

This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.

Opinion

PER CURIAM.

This case presents a factual situation indistinguishable for the purposes of the controlling legal principle from our deci *716 sion in United States v. Eidson, (5th Cir. 1962) 310 F.2d 111. It follows that the decision of the Tax Court, that amounts received by the taxpayers upon assignment of their rights under a general agency contract for a Texas statewide mutual assessment life insurance company were taxable as ordinary income, was correct, and that it should be and is affirmed.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.